No Means No…and So Does a TDO!

2015/10/01

By: Danielle McClellan

On March 19, 2015, a Temporary Denial Order (TDO) was put in place for Flider Electronics LLC, d/b/a Trident International Corporation, Pavel Semenovich Flider (President of Trident), and Gennadiy Flider (Trident office manager) for 180 days. The TDO denied the export privileges of the above mentioned parties as well as prohibited them from participating in any way, in any transaction involving any item subject to the EAR that is to be exported from the US, including carrying on negotiations concerning, ordering or buying any such items…this is important to this story.

Beginning in 2013, Flider and/or Trident repeatedly exported Xilinx field programmable gate array (FPGA) circuits (ECCN 3A001.a.2.c) to Russia without the required export license. CBP ultimately seized some of the shipments. After additional seizures, another detained shipment and interviews by Pavel Flider and Gennadiy Flider, OEE had reason to believe that Trident had been making transshipments to Russia. In addition, Trident and Pavel Flider were indicted for smuggling and money laundering. There is much more to this story…but I have kept it short for the purposes of this article. View more details at: http://learnexportcompliance.bluekeyblogs.com/2015/04/27/potential-poster-child-for-violating-us-export-controls-on-russia-flider-electronics-put-on-the-u-s-denial-list-for-shipments-to-russia/

Now comes the interesting part of the story. The TDO denies negotiations concerning, and ordering items subject to the EAR as mentioned above. After laying low for a few months after the initial TDO, on July 10, 2015, Trident, via Pavel Flider, contacted employees of their previous electronics distributor requesting their account to be reestablished so that additional purchases could be made. The distributor declined to accept or fill any orders following several solicitations by Pavel Flider, including a phone call by him to the company where he was strictly informed that the company’s corporate policy was that they could not conduct business with a company such as Trident.

After this information came to light, OEE requested the TDO be renewed on August 21, 2015.

View both TDO’s: http://efoia.bis.doc.gov/index.php/electronic-foia/index-of-documents/7-electronic-foia/227-export-violations

Comments are closed.